How Many States Require This Now
At least 15 states plus Washington, D.C. currently have pay-transparency or salary-range-disclosure laws on the books, per Jackson Lewis LLP’s own tracking of employer obligations. That is a meaningfully larger footprint than most staffing firms are actively planning around, and it keeps growing: new requirements are being signed into law or taking effect on a near-constant basis rather than settling into a fixed, memorizable list.
The Threshold Variation That Trips Firms Up
The employer-size threshold and the exact requirement differ meaningfully state by state, which is where a firm assuming one national rule gets into trouble. California requires pay scales in job postings for employers with 15 or more employees, with an effective clarification arriving January 1, 2026 through SB 642. Colorado applies its law to any employer with at least one Colorado employee, including a fully remote role, no size threshold at all. Connecticut requires disclosure upon request or before an offer for all employers. Illinois requires both a pay scale and benefits information for employers with 15 or more employees, plus a separate requirement to notify employees of promotions within 14 days.
New York requires a compensation range in postings for employers with 4 or more employees. Washington requires a salary range or fixed wage for employers with 15 or more employees, with a five-business-day cure period for first violations running through July 27, 2027. Washington, D.C. requires a minimum and maximum projected pay in listings for any employer with at least one employee, and separately requires healthcare benefits to be disclosed before the first interview.
Colorado’s own no-threshold rule goes deeper than that headline suggests. A separate national labor and employment law firm’s analysis of Colorado’s own INFO #9A guidance, Ogletree Deakins, confirms the state’s current pay-transparency amendments took effect January 1, 2024, and require postings to disclose the salary or wage range, a general description of other compensation and benefits, and either the application deadline or a statement that applications remain open. Colorado goes further than a posting-only obligation, too: within 30 days of hiring, an employer must notify the Colorado employees it works with regularly about the hire itself, including the new employee’s name and title and how those employees can indicate interest in similar opportunities in the future, a post-hire disclosure duty most other states on this list do not impose.
Why This Is Still Expanding, Not Settling
Jackson Lewis’s own tracking names newly effective or upcoming requirements beyond the states above: Delaware’s law, covering employers with 26 or more employees, takes effect September 26, 2027, and New Jersey has recently signed its own pay-transparency requirements into law. Neither of those is a hypothetical future possibility, both are confirmed, dated developments already on the books as of this writing.
That pattern, new states and new effective dates arriving on a rolling basis rather than a periodic update cycle, is exactly why a staffing firm needs an ongoing compliance process for this topic, not a single reference document checked once and filed away.
What This Means for a Staffing Firm Specifically
A staffing firm posting job orders on behalf of clients, or posting its own openings, across even a handful of these states is managing fifteen-plus separate sets of requirements simultaneously, not one. Some of that burden falls on whichever party controls the job posting itself, which is not always the staffing firm, a real coordination question a firm needs to settle with each client rather than assume defaults one way or the other.
The Honest Caveat on These Specific Figures
Jackson Lewis is a national labor and employment law firm publishing its own client-alert analysis, qualified professional legal commentary rather than a primary government source for each individual state’s statute. Every threshold and effective date named above is worth re-verifying against that state’s own current law before it gets repeated to a client as settled fact, particularly given how frequently this specific area of law is changing.
Turning Compliance Fluency Into a Real Differentiator
A staffing firm that can speak accurately to a client’s own pay-transparency obligations in the state where a role is posted is demonstrating exactly the kind of operational depth that separates a real partner from a firm that only shows up once a job order is already open. Human + AI SDRs can help a staffing firm get in front of the hiring managers who would value that depth, before a competitor with less multi-state fluency gets there first.
Sources
The external data in this article draws on the sources below. Figures described in the text as estimates or industry triangulations are directional and are not attributed to a single dataset.
- Jackson Lewis LLP, Navigating 2026: Pay Transparency Laws and Employer Obligations
- Ogletree Deakins, Colorado Issues Official INFO Guidance on Pay Transparency Amendments